T.C. Memo. 2000-106
UNITED STATES TAX COURT
THOMAS F. AND TOYIA A. NOONS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11163-98. Filed March 28, 2000.
James A. Cerks, for petitioners.
Susan M. Pinner, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge: Respondent determined a $35,080 deficiency in
petitioners’ 1993 Federal income tax and a $2,490 addition to tax
pursuant to section 6651(a)(1). The deficiency arises from
respondent’s reclassification of a $197,234 legal fee deduction
petitioners claimed on Schedule C as a Schedule A deduction. As a
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